I’ve been asked by Simon to post this email trail on the forum for feedback:
Original question (email 4th May):
Whilst working through the Confirmation statement specifications we have a key question (see point 1) for our understanding of the process.
For information related to PSCs
For example in Company 1 Ltd, one of its PSCs has had changes:
a. Surname on the 3rd July 2016 from Smith to Jones
b. Residential Address on the 4th July 2016 from 5 Crescent Avenue, London WC2 4ED to 5 Longarce, LONDON, WC1 5RD
c. PSC details on the 5th July 2016 from 25% or more of the shares to 50% or more of the shares
Q. Are we able to just submit a confirmation statement on the 7th July for Company 1 Ltd (when our first Confirmation statement was due, based on Last Annual Return being 7th July 2015) showing the current position:
Address: 5 Longarce, LONDON, WC1 5RD
PSC Details: 50% or more of the shares
OR are we expected to submit three separate changes for each day and each event in the order they occurred in the confirmation statement for this PSC?
Beth’s reply (email 8th May)
Technically, you should enter three separate dates, if the changes have been entered in the company’s PSC register on three different dates. However, if you were to do this electronically (web or software), you will have to submit three separate confirmation statements. Alternatively, if the changes are recorded as being on the same date in the company’s PSC register, you can submit all the changes as part of the one confirmation statement (web or software). Another option is that you could file the separate changes on different dates on one paper confirmation statement.
Follow up (email 12th May)
Q1. I note your answer in your earlier email, for point 1 related to the response “However, if you were to do this electronically (web or software), you will have to submit three separate confirmation statements.,”. Having looked at the E-Filing specifications it seems as though it should be possible to show the three transactions for one PSC within one Electronic confirmation statement as you could on paper, by “repeating” updates for a PSC in the one message. Could we please get clarification on this point as understanding this is key?
Otherwise, if clients are E-filing a confirmation statement annually it could involve submitting hundreds of separate confirmation statements for the PSC Part 5. Having looked at the CS01 paper version it may be more sensible to submit paper not electronically.